This Notice (together with the Website Terms and Conditions and any other documents referred to on it) sets out the basis on which GwenGreen Virtual Assistant Services (“GG VAS”), Dagenham, Essex will process any personal data we collect from you, or which you provide to me in the course of using my site www.gwengreen.co.uk (“Site”).
For the purpose of the Data Protection Act 1998, I am the data controller and registered with the Information Commissioner’s Office under Registration Number ZA422197.
Here at GG VAS, your privacy is taken very seriously, and I will only use your data to administer to your account and provide you with the products and services that you have requested.
1. What this Notice covers
This Privacy Information explains how I use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
2. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that I use is set out in Section 4 below.
3. Your Rights
Under the GDPR, you have the following rights, which I will always work to uphold:
a) The right to be informed about collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Section 10.
b) The right to access the personal data I hold about you. Section 9 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Section 11 to find out more.
d) The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I have. Please contact me using the details in Section 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to me using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to me directly, OR I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. I do not use your personal data in this way.
For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Section 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
4. What Personal Data is collected
I may collect some or all of the following personal data (this may vary according to your relationship with me):
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Information about your preferences and interests;
- Membership Information (Clubs, Frequent Flyer accounts);
- Payment Information;
- Passport Information (for booking travel);
- Driving Licence Information (for booking travel);
- Online logins that you have shared with me for purposes of completing specific tasks (such as booking travel on an airline account).
5. How your Personal Data is used
Under the GDPR, I must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Supplying my services to you. Your personal details are required in order for me to enter into a contract with you.
- Personalising and tailoring my services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the opt-out link in any newsletter sent.
- To perform my services for you.
With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message with information, news, and offers on my services. You will not be sent any unlawful marketing or spam. I will always work to fully protect your rights and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
6. How long your Personal Data is kept for
I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for six years.
7. How and where your Personal Data is stored or transferred to
I may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that I will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
I share your data with external third parties, as detailed below in Section 8, that are based outside of the EEA. The following safeguard[s] are applied to such transfers:
I will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.
Where I transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact me using the details below in Section 11 for further information about the particular data protection mechanism used by me when transferring your personal data to a third country.
The security of your personal data is essential to me, and to protect your data, I take a number of important measures, including the following:
- all of my hardware is encrypted;
- use multi-factor authentication where possible, alongside multi-step passwords;
- use GDPR compliant software, with servers either in Europe or; where within the US, employ the US EU Privacy-Shield Framework;
- all hard copies are kept to a minimum, but where there are hard copies, they are stored within locked cabinets.
8. Sharing your Personal Data
I will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
9. How you can access your Personal Data
If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Section 11. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to my administrative costs in responding. I will respond to your subject access request within one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.
10. Website Privacy – what data is collected
- business/company name
- contact information such as email addresses and telephone numbers;
- IP address;
- website address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on My Site, and the site you exit to;
11. How you can contact me
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please email me here.
12. Changes to this Privacy Notice
I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.